Assessee a Russia based company, participated in water supply augmentation project and oil pipeline project etc. through its PE in India, since there was no transfer of any technical know-how and, moreover, entire payment received during year was attributable to PE in India, same was taxable as business profit in terms of India-Russia DTAA. (AY. 2004 -05, 2005-06, 2006-07)
PJSC Stroytransgaz v. DCIT (2019) 177 ITD 538 (Delhi)(Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection–Water supply augmentation project and oil pipeline project etc- Payment received during year was attributable to PE in India, same was taxable as business profit-DTAA-India–Russia [Art. 7, 12]